BCC PRIVACY POLICY
UNDER Data Privacy Act of the Philippines (R.A No. 10173)
Baguio Country Club Corporation (collectively referred to as “the Club”, “we”, “us” or “our”)
recognizes the importance of protecting your personal data.
This Privacy Policy defines how we collect, protect, manage, and disclose information from you
through our downloadable forms from our website, telephone calls, email, verbally, and printed
forms.
The Club respects and values the confidentiality of Personal Information and is committed to
comply with the Philippine Data Privacy Act of 2012. We value data privacy rights, and we will
make sure that all personal information collected from our members, guests, visitors, suppliers,
vendors, partners, clients, employees, associates and other stakeholders are processed in adherence
to the general privacy principles of transparency, legitimacy of purpose and proportionality.
The website is intended for public viewing and reference purposes only and the Club does not
perform any transactions on it. We do not collect personal information from the website using
electronic forms or any third-party links.
I. PROCESSING OF PERSONAL DATA
A. COLLECTION
The Club does not collect any information from the website using electronic forms. Collection of
information using the downloadable forms are only done when a data subject inquires information
or services by calling the respective offices of the Club using the chat box, contact numbers and
email addresses posted in the website contact page, we may ask for personal information with Data
Consent to process the inquiry or transaction. The following BCC services requires to collect
personal information from the members and guests.
When you request for a particular service from us, we may or will ask for your Personal Data (e.g.,
name, address, and contact information, medical information, membership information,
credit card payment, triage certificate, health declaration form, medical history, vaccination
info, PWD Card, Senior Citizen Card and other sensitive information) for us to process your
transaction. Below are the transactions where we will or may collect your personal data:
a. Membership Application
Collection of personal information and sensitive personal information from the applicants is only
through downloadable forms and must only be submitted to the mailing addresses presented on
the site.
Collected information are addressed with strict confidentiality and also applying the general data
privacy principles as the requirement for the membership is to disclose sensitive personal
information including but not limited to: spouse’s and children’s information, professional
certification, club memberships, bank and credit references, pending civil or criminal cases in the
Philippines or Abroad and records of disciplinary action from other Clubs.
Baguio Country Club is an exclusive membership club and caters prestigious names in the
Philippine society. Sensitive personal information are collected to prove the identity of the
applicant and that he/she has no criminal records.
We may also collect information from other members regarding personal data to further assess the
application.
b. Booking and Reservations
Upon receipt your reservation inquiry, our personnel will redirect you to our Reservations
Officer who will then book your reservation details in our computer system.
c. Golf / Recreation / Sports / Wellness Activities/ Programs/ Events
Upon receipt your inquiry, your Personal Data will be collected during your facility
reservation, registration / availment in any of our golf, sports and recreational
activities/programs, especially when you sign for transactions as a result of availing of any
of the services.
d. Food, Beverage / Dining Services
Upon receipt your table or product reservation inquiry in any of our outlets/restaurants, we
will collect your Personal Data for the purpose of recording your transactions with us.
e. Events and Banquet Arrangements
When you book any event with us through our function venues and meeting rooms, we will
collect your Personal Data for the purpose of recording arrangements and other transactions
with us.
f. Outlets managed by our concessionaires for the Salon, Pro Shop and Gift Shop.
When you avail of our concessionaire’s products and services in any of our
outlets/restaurants, we will collect your Personal Data for the purpose of recording your
transactions with us.
g. HR Job Hiring
When you ask about the requirements and the process for submitting a job application.
h. Health and Safety
When you disclose to us your personal information as requirements for COVID-19
protocol prior to entering the Club.
i. We also collect personal and sensitive information:
• When we receive references from third parties or our business partners (i.e. when you
have been referred by them).
• When you submit your personal information to us for any other reason.
When you disclose to us another person’s personal information (i.e. your dependent, spouse,
children and/or parents) you attest that consent has been obtained from that person to disclose and
process personal information in accordance with this policy.
By affixing the signature of the applicant under the Data Privacy Consent included in the form,
the applicant hereby authorizes and consents to the use, collection, access, transfer, storage and
processing of said personal data.
B. USE
Personal data collected shall be used by the Club for documentation purposes. The Club shall
ensure that processes are updated and that the consent of the data subjects is properly obtained.
Such procedures will be regularly monitored, modified, and updated to ensure the rights of the
data subjects are respected and that the collection is done fully in accordance with the Data Privacy
Act of 2012 and other applicable laws and regulations.
The Club collects uses your Personal Information for the following purposes:
1. Provide you with products, facilities, and services that you have requested,
including member- client / customer service support and after sales / events
support;
2. Enhance your Club experience by delivering products, facilities and services that
match your preference and needs;
3. Communicate relevant services, advisories including responses to your queries,
requests, and complaints;
4. Provide information about the Club’s products, facilities and services which may
be of interest to you;
5. Comply with the requirements of the law and legal proceedings such as court
orders; comply with legal obligation or to prevent imminent harm to public
security, safety, or order;
6. To prevent, detect and investigate incidents or crime, including fraud and cyber
crimes;
7. Process information for statistical, analytical and research purposes.
Other uses by nature of our dealings
Aside from the general uses mentioned previously, we may use your personal
information depending on your dealings with us in any of the following manner:
a. When you inquire or purchase a proprietary share or apply to become a
member / resign or cancel your membership or sell your proprietary share
• To conduct appropriate due diligence checks.
• To register your inquiry and address any follow-up calls.
• To prepare all necessary documentation as may be requested.
• To perform all financial processes related to the membership or sale such as the
setup of down payment, amortization or financing , if applicable, and perform
other actions necessary or desirable in the implementation of our contract /
agreement or processing of your membership or its transfer, cancellation and/or
termination.
• To manage all administration and turn over activities.
• To communicate all advisories and changes in relation to the sale or disposition.
• Any other purpose relating to any of the above.
b. When you apply to become a merchant, concessionaire or tenant in any of our
properties / spaces for lease
• To conduct appropriate due diligence checks.
• register and process your application / accreditation.
• To prepare documentation and any other documents as may be required.
• To perform financial transactions such as the processing of payments and
perform other actions necessary or desirable in the implementation of our
contract.
• To communicate any advisories or changes in terms and condition related to your
contract.
• Any other purpose relating to any of the above
c. When you are a supplier, vendor, service provider, a prospective vendor or a
contractor
• To conduct appropriate due diligence checks.
• To evaluate your proposal and to conduct corresponding background checks.
• To assess your viability as a supplier / vendor / service provider and process your
accreditation.
• To communicate with you about matters relating to our required products and
services.
• To perform other actions necessary or desirable in the implementation of our
contract.
• Any other purpose relating to any of the above.
d. When you apply for employment or become our employee
To process your application including any of the following:
1. For recruitment;
2. Conducting a background check and vetting;
3. Conducting aptitude and personality tests and checks.
e. When you are our shareholder / proprietary member
• To administer the relationship such as identification verification including
identity of your nominated proxy.
• Communicate the Club’s performance including products, facilities and
services as well as changes in polices, terms and conditions through various
medium applicable.
• Any other purpose relating to any of the above.
f. Medical history and health protocols
To comply with the National Government regarding health protocols for every
establishment.
C. STORAGE, RETENTION AND DESTRUCTION
1. Storage
Collected physical data are stored in organized and secured storages accessible only to
authorized personnel with the use of keycards. Electronic data gathered are stored in
secure servers.
2. Retention
We will retain documents containing your personal data:
- to the extent that we are required to do so by law;
- to the extent required by or pursuant to our contract;
- if we believe that the documents may be relevant to any ongoing or prospective
legal proceedings;
- if documents are in low risks the minimum retention is 3 years. Nonetheless,
our minimum retention period for significant data is between five and ten years;
- if we believe that the documents are need to be use for historical documentation,
statistical, analytical and research purposes
- We are not storing personal data submitted in any social media platforms.
- Deletion of personal information in emails and other social media conversation
when the purpose is done.
3. Destruction
- Thereafter your personal information shall be disposed or discarded in a secure
manner that would prevent further processing, unauthorized access, or
disclosure to any other party or the public;
- Files containing personal information will be crushed and shredded, regardless of
whether they are stored on paper, film, optical, or magnetic media.
- It is the organization’s duty to make sure that data will be disposed properly in
a way that the data should be unreadable (for paper) or irretrievable (for digital
records).
D. ACCESSING AND UPDATING
Accessing your personal information
You may instruct us to provide you with any personal information we hold about you.
Provision of such information will be subject to the supply of appropriate evidence of
your identity.
Updating your personal information
If the personal information that we hold about your needs to be corrected or updated,
The Club shall make all reasonable efforts to ensure that data collected is current,
complete and accurate. If you wish to access and update your personal data, you may
send the request to dpo@bcc.com.ph or get in touch with respective division,
department or office which provided the product or services that you have engaged
with. As part of our security measures, we will contact you and conduct the necessary
verification measures to process your request. Once we have implemented the
necessary correction we shall then notify you that your request has been processed.
Withdrawal of consent
If you wish to withdraw your consent given for any or all purposes set out in this Policy,
you may send your detailed request to dpo@bcc.com.ph. Depending on the nature of
your consent withdrawal, the Club may not be in a position to continue to provide our
products, facilities and services to you.
E. DISCLOSURE
1. We may disclose your personal information to the following as reasonably
necessary depending on the product, facility and service concerned:
• Our Employees, Board of Directors, Officers, Management, Advisors and
Standing Committees;
• Professional advisers such as lawyers and auditors;
• Insurers and credit providers, whenever applicable or warranted;
• Banks, credit card companies and their respective service provider;
• Suppliers or subcontractors, third party service providers , consultants that
have been contracted by the Club to provide financial, technical,
architectural, administrative services such as information technology,
payroll, accounting, sales administration, procurement, training and other
services;
2. We may disclose your personal information:
▪ To the extent that we are required to do so by applicable law and/or rules
and regulations;
▪ In connection with any ongoing or prospective legal proceedings;
▪ To the buyer or prospective buyer of any proprietary share, business or asset
that we are contemplating to sell;
▪ To any person who we reasonable believe may apply to a court or other
competent authority for disclosure of such personal information where, in
our reasonable opinion, such court or authority would be reasonably likely
to order disclosure of such personal information;
▪ Any company with which we share information about you is required to
comply with confidentiality standards, Data Sharing Agreement, NDA,
undertake to respect any individual’s right to privacy and comply with the
Philippine Data Privacy Act.
II. SECURITY MEASURES
The Club implements reasonable and appropriate organizational, physical and technical security
measures for the protection of personal data against natural dangers such as accidental loss or
destruction and human dangers such as unlawful access, fraud, alteration and contamination.
A. ORGANIZATIONAL SECURITY MEASURES
- We established an internal data protection officer with a separate department
focused solely on data privacy tasks.
- The Club’s Data Privacy Protection and Security Committee (DPPSC) has been
created to ensure the Club’s Compliance to Republic Act 10173 or the Data Privacy
Act of 2012.
B. PHYSICAL SECURITY MEASURES
- To create a more orderly and effective environment, the Club is
implementing the 5S concept.
- The Club maintains an annual update to its own data privacy manual.
- To keep its workers informed of data privacy laws, the Club conducts annual
data privacy training.
- The Club has a Non-disclosure and Data Sharing Agreement for outsourcing
services.
C. TECHNICAL SECURITY MEASURES
For Website
The Club uses Secure Socket Layers, SiteLock and Domain Privacy. These
programs protect the website from hackers, spam and malware. However, total
protection is not guaranteed. Baguio Country Club is not responsible for any
damage, harm or loss incurred to you by giving personal information on the internet.
Furthermore, the Club acknowledges the dangers doing processes online hence, the
Club does not provide any transactions via website.
For Data Centers
The secure on-site data center is managed by a dedicated IT department. The Club's
electronic systems were created for desktop use and are only accessible over the
intranet.
Electronic Portals
- To handle the data life cycle easily, the Club developed its own electronic
data inventory and data procedure request forms.
- The Electronic Clearances and Access of Employees, Members, Guests,
Visitors, and Suppliers are strictly enforced by the Club.
III. YOUR RIGHTS
You have the option to choose which personal information you are comfortable to share with us.
However, if you choose not to provide the personal information that we need or are mandatory in
processing your transaction, we may not be able to process the requested services or complete your
transaction.
Right to Be Informed
The data subject shall be notified and furnished via email, verbal or written documents with
information indicated hereunder before the entry of his or her personal data into the records of the
Club.
Right to Object
You have the right to object and to erasure and blocking of your personal information. The Club
may restrict your limits to accessible facilities and services or deny transactions when you exercise
these rights.
Right to Access and Rectification
You may instruct us to provide you with any personal information we hold about you. Provision
of such information will be subject to the supply of appropriate evidence of your identity. You
have the right to rectify your personal data if you find any information that needs updating or
correction.
Right to Erasure or Blocking, And Damages
The data subject shall have the right to suspend, withdraw, or order the blocking, removal, or
destruction of his or her personal data from the Club’s filing system.
This right may be exercised upon discovery and substantial proof data is no longer necessary for
the purposes
Right to Transmissibility
In situations where the data subject is unable to exercise his or her rights, the data subject's legal
heirs and assigns may make use of the rights of the data subject to which they are entitled.
You have the right to file a complaint and seek damages incurred to you.
If you wish to withdraw your consent given for any or all purposes set out in this Policy, you may
send your detailed request to the contact information below. Depending on the nature of your
consent withdrawal, the Club may not be able to continue to provide our products, facilities and
services to you.
IV. CONTACT US
Any concerns or inquiries with respect to your Personal Data may be sent to our designated Data
Privacy Officer, with the following contact details below:
• Email us at dpo@bcc.com.ph
• Contact us at +6374 6192050 to 60
